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I In support of their argument, Petitioners cite the introduction section to the Metro Plan's <br />2 Parks and Recreation Facilities Element and finding 5 of that element; neither the introduction <br />3 nor the findings have any binding legal effect." Rather, it is the Metro Plan policies to which <br />4 the City must comply. The Metro Plan policy related to private recreation facilities states: <br />5 "Encourage the development of private recreational facilities." (App. 9). The PROS Plan <br />6 contains the following strategies that address this Metro Plan policy: <br />7 A -16 Increase outreach to community groups and other organizations that <br />support seniors, such as assisted living facilities and other faith groups. <br />8 (Rec. 75). <br />9 A -23 Explore partnerships to expand outdoor recreation activities and <br />programs that promote environmental awareness, volunteerism, and <br />10 stewardship, including options that are affordable. (Rec. 75). <br />11 A -37 Partner /collaborate with resident companies and other cultural venues to <br />provide cultural opportunities. (Rec. 76). <br />12 <br />C -2 Develop and maintain partnerships to increase access to recreation <br />13 facilities owned or managed by others. (Rec. 82). <br />14 C -27 Develop partnerships with gardening and horticultural clubs, such as the <br />Master Gardeners, the Hardy Plant Society, the Native Plant Society, and <br />15 the Rhododendron and Rose Societies, to enhance existing gardens and <br />to provide additional botanical gardens. (Rec. 84). <br />16 <br />H -12 Pursue local business sponsors to subsidize fees for high -cost programs <br />17 such as through an "Adopt -A- Program" effort. (Rec. 93). <br />18 H -16 Partner with businesses to provide services and amenities, such as <br />vendors in parks. (Rec. 93). <br />19 <br />H -17 Pursue and maintain effective partnerships with public, private and non - <br />20 profit organizations to acquire, develop, and maintain parks, open space, <br />and recreation facilities. (Rec. 93). <br />21 <br />2� The PROS Plan adequately encourages the development of private recreation facilities. <br />23 As such, the PROS Plan is consistent with the Metro Plan. Accordingly, LUBA should deny <br />24 Petitioners' seventh assignment of error. <br />25 <br />26 10 Section I -4 of the Metro Plan states: "A finding is a factual statement resulting from investigation, <br />analysis, or observation." A policy statement is a "statement adopted as part of the Pima to provide a consistent <br />course of action, moving the community towards attainment of its goals." <br />Page 2 - BRIEF OF RESPONDENT <br />